TOXIC REDUCTION POLICY STATEMENT OF INTENT

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1 TOXIC REDUCTION POLICY STATEMENT OF INTENT Hexachlorobezene is created and released at the DeBeers Canada Inc Victor Mine site during the incineration of mine waste. Although the camp facility at the Victor Mine practices a high degree of substitution and segregation of plastic wastes prior to incineration, a significant fraction of the waste stream consists of plastic food packaging etc. that must be incinerated for sanitary reasons. There are no viable options to incineration for this waste; land-filling of putrescible waste is not an option due to the high water table in the surround muskeg wetland, and the isolated location with only seasonal access via a 400 km ice road prevents effective shipment of these wastes for off-site disposal. De Beers Canada Inc., Victor Mine is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate or reduce the creation and discharge of Hexachlorobezene in full compliance with all federal and provincial regulations. Our employees are encouraged to participate in all types of toxic substance reduction activities. Toxic substance reduction will be an ongoing effort at DeBeers, and we will continue to monitor advancements to ensure that options that are both technologically and financially viable are implemented at our facility. REDUCTION OBJECTIVES There was no reduction option indentified because there is no viable way of reducing use and creation of Hexachlorobezene. Hexachlorobezene is not brought into the site but is created and released during the incineration of mine waste. In addition, the incinerator emissions have met the reporting criteria for the Toxic Reduction Act, although at extremely low levels, because emissions below the level of detection were required to be reported as if they were in fact occurring at the Method Detection Limit. Consequently, there are few practical options for lowering the emissions reported, which are for the most part not scientifically quantifiable. DeBeers Canada Inc has made recent plant improvements. All employees at the Victor Mine will be involved in waste reduction efforts. Waste Segregation will be one of our first priorities for reduction. Our goal is to reduce the use of plastic substances where technically and economically feasible. Steps taken include a reduction in plastic use and employee education to help with waste segregation. PLAN SUMMARY STATEMENT This plan summary accurately reflects the content of the toxic substance reduction plan for Hexachlorbenzene, prepared on behalf of De Beers Canada Inc., Victor dated Dec 22, 2012.

2 BASIC FACILITY INFORMATION Company Name: DeBeers Canada Inc., Victor Mine Contact Information: 119 Pine St. South, Suite 310, Timmins, ON. P4N 2K3 Highest Ranking Employee: James Kirby Mine General Manager Ext Technical Contacts: or Brian Steinback P. Eng Terry Ternes P.Geo ext 5779 Certified Planner: Parent Company: Address: Tony van der Vooren P.Eng, Ph.D, QEP License Number TSRP0051 Senior Environmental Consultant Amec Americas Limited De Beers Canada Inc. 100% ownership Suite Ferrand Dr. Toronto, Ontario M3C 3G8. Business Number: The facility s NPRI ID: full time employees (equivalent). Site Location (UTM Coordinates): E and N The NAICS codes applicable to the facility are: 21 - Mining, quarrying, and oil and gas extraction 2123 Non metallic mineral mining and quarrying Diamond Mining Company Name: DeBeers Canada Inc.

3 The site emits trace levels of Hexachlorobenzene and total Dioxins and Furans (including the individual congeners*) which are part of Phase 1 MOE Toxic compounds list. *(A Separate Plan has been developed for and total Dioxins and Furans (including the individual congeners) Hexachlorobenzene

5 TOXIC REDUCTION POLICY STATEMENT OF INTENT De Beers Canada Inc., Victor Mine is committed to playing a leadership role in protecting the environment. Wherever feasible, we will eliminate or reduce the creation and discharge of Dioxins and Furans in full compliance with all federal and provincial regulations. Our employees are encouraged to participate in all types of toxic substance reduction activities. Toxic substance reduction will be an ongoing effort at DeBeers, and we will continue to monitor advancements to ensure that options that are both technologically and financially viable are implemented at our facility. Dioxins and Furans (including individual congeners) are created and released at the DeBeers Canada Inc Victor Mine site during the incineration of mine waste. Although the camp facility at the Victor Mine practices a high degree of substitution and segregation of plastic wastes prior to incineration, a significant fraction of the waste stream consists of plastic food packaging etc. that must be incinerated for sanitary reasons. There are no viable options to incineration for this waste; land-filling of putrescible waste is not an option due to the high water table in the surrounding muskeg wetland, and the isolated location with only seasonal access via a 400 km ice road prevents effective shipment of these wastes for off-site disposal. REDUCTION OBJECTIVES There was no reduction option was indentified because there is no viable way of reducing use and creation of Dioxins and Furans. Dioxins and furans are not brought into the site but are created and released during the incineration of mine waste. In addition, the incinerator emissions have met the reporting criteria for the Toxic Reduction Act, although at extremely low levels, because emissions below the level of detection were required to be reported as if they were in fact occurring at the Method Detection Limit. Consequently, there are few practical options for lowering the emissions reported, which are for the most part not scientifically quantifiable. DeBeers Canada Inc has made recent plant improvements. All employees at the Victor Mine will be involved in waste reduction efforts. Waste Segregation will be one of our first priorities for reduction. Our goal is to reduce the use of plastic substances where technically and economically feasible. Steps taken include a reduction in plastic use and employee education to help with waste segregation. PLAN SUMMARY STATEMENT This plan summary accurately reflects the content of the toxic substance reduction plan for Dioxins and Furans (Including Individual Congeners), prepared on behalf of De Beers Canada Inc., Victor Mine dated December 22, 2012.

6 BASIC FACILITY INFORMATION Company Name: DeBeers Canada Inc., Victor Mine Contact Information: 119 Pine St. South, Suite 310, Timmins, ON. P4N 2K3 Highest Ranking Employee: James Kirby Mine General Manager Ext Technical Contacts: or Brian Steinback P. Eng Terry Ternes P.Geo ext 5779 Certified Planner: Tony van der Vooren P.Eng, Ph.D, QEP License Number TSRP0051 Senior Environmental Consultant Amec Americas Limited Parent Company: Address: De Beers Canada Inc. 100% ownership Suite Ferrand Dr. Toronto, Ontario M3C 3G8. Business Number: The facility s NPRI ID: full time employees (equivalent). Site Location (UTM Coordinates): Zone 17, E and N The NAICS codes applicable to the facility are: 21 - Mining, quarrying, and oil and gas extraction 2123 Non metallic mineral mining and quarrying Diamond Mining Company Name: DeBeers Canada Inc.

7 The site emits trace levels of total Dioxins and Furans (including the individual congeners specified below) and Hexachlorobenzene* which are part of Phase 1 MOE Toxic compounds list. *(A Separate Plan has been developed for Hexachlorobenzene) Dioxins and Furans individual congeners HpCDD(Dioxin) HpCDF(Furan) HpCDF(Furan) HxCDD(Dioxin) HxCDF(Furan) HxCDD(Dioxin) HxCDF(Furan) HxCDD(Dioxin) HxCDF(Furan) PeCDD(Dioxin) PeCDF(Furan) HxCDF(Furan) PeCDF(Furan) TCDD(Dioxin) TCDF(Furan) Octa CDD (Dioxin) Octa CDF (Furan)

10 Debeers Canada Inc. Toxics Reduction Plan for Metals Victor Mine December 2013 TOXIC REDUCTION POLICY STATEMENT OF INTENT De Beers Canada Inc., Victor Mine is committed to playing a leadership role in protecting the environment. Our employees are encouraged to participate in all types of toxic substance reduction activities. Toxic substance reduction will be an ongoing effort at DeBeers, and we will continue to monitor advancements to ensure that options that are both technologically and financially viable are implemented at our facility. Metals are not created or used at the DeBeers Victor Mine site but are naturally contained in ore (kimberlite) from which diamonds are extracted. After processing the kimberlite, it is transferred into an onsite tailings management pond. The fine processed kimberlite transferred to the pond contains arsenic, cadmium, chromium, cobalt, copper, lead, manganese, nickel, selenium, vanadium and zinc. In addition there are trace amount of metals emitted and transferred from the operation of the onsite waste incinerator. This represents less than 0.01% of the total metals reported. DeBeers already employs waste diversion to reduce the amount of plastics, metals and batteries entering the incinerator, in addition the incinerator is equipped with advanced air pollution control (scrubbers) to minimize emissions to air. REDUCTION OBJECTIVES DeBeers does not intend to reduce the transfer of metals because these substances are naturally occurring in ore from which diamonds are extracted and eventually disposed into the onsite tailings management pond. The only way to reduce the amount of metals transferred to the tailings facility would be to reduce the amount of ore processed, which could only be obtained by reducing output and plant operations. DeBeers is committed to ensuring their tailings transfers are handled in a safe and responsible manner. While DeBeers does not intend to reduce the transfer of the aforementioned metals, technologies that may reduce the releases to the environment of these substances will be monitored. PLAN SUMMARY STATEMENT This plan summary accurately reflects the content of the toxic substance reduction plan for Metals (arsenic, cadmium, chromium, cobalt, copper, lead, manganese, nickel, selenium, vanadium and zinc) prepared on behalf of De Beers Canada Inc., Victor Mine dated December 23, 2013.

11 Debeers Canada Inc. Toxics Reduction Plan for Metals Victor Mine December 2013 BASIC FACILITY INFORMATION Company Name: DeBeers Canada Inc., Victor Mine Contact Information: 119 Pine St. South, Suite 310, Timmins, ON. P4N 2K3 Highest Ranking Employee: James Kirby Mine General Manager Ext Technical Contacts: Certified Planner: Parent Company: or Brian Steinback P. Eng Terry Ternes P.Geo ext 5779 Tony van der Vooren P.Eng, Ph.D, QEP License Number TSRP0051 Senior Environmental Consultant Amec Americas Limited De Beers Canada Inc. 100% ownership Address: Suite Ferrand Dr. Toronto, Ontario M3C 3G8. Business Number: The facility s NPRI ID: full time employees (equivalent). Site Location (UTM Coordinates): Zone 17, E and N The NAICS codes applicable to the facility are: 21 Mining, quarrying, and oil and gas extraction 2123 Non metallic mineral mining and quarrying Diamond Mining Company Name: DeBeers Canada Inc. This Toxic Reduction plan was prepared for arsenic, cadmium, chromium, cobalt, copper, lead, manganese, nickel, selenium, vanadium and zinc. Separate toxic reduction plans have been developed for dioxins and furans individual congeners, hexachlorobenzene, carbon monoxide and particulates (TPM, PM10 and PM2.5).

12 Debeers Canada Inc. Toxics Reduction Plan for Metals Victor Mine December 2013 Arsenic NA-02, Cadmium NA-03, Chromium NA-04, Cobalt NA-05, Copper NA-06, Lead NA-08, Manganese NA-09 Nickel NA-11, Selenium NA-12 Vanadium Zinc NA-14

14 Debeers Canada Inc. Toxics Reduction Plan for Metals Victor Mine December 2013 CERTIFICATION OF LICENSED PLANNER As of December 23, 2013, I, Tony van der Vooren certify that I am familiar with the processes at DeBeers Victor Mine that use or create the toxic substance referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the plan dated [insert version date] and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act (except for the plan submission by Dec 31, 2012). Arsenic NA-02, Cadmium NA-03, Chromium NA-04, Cobalt NA-05, Copper NA-06, Lead NA-08, Manganese NA-09 Nickel NA-11, Selenium NA-12 Vanadium Zinc NA-14 Tony van der Vooren P.Eng, Ph.D, QEP Licensed Toxic Reduction Planner (Ontario): License Number TSRP0051 Senior Environmental Consultant AMEC Americas Limited